Interest Disallowance on CWIP Challenged; Evidence Shows Unsecured Loans Used for Working Capital, Not Diverted Elsewhere.

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....Disallowance of interest relating to Capital Work in Progress (CWIP) - The Appellant has furnished the relevant working capital facility agreements and ledger account to show that the unsecured loans were for working capital, and the interest paid thereon is also clearly reflected in the financial statements in Schedule 18 - “Interest – On working capital loans”. In our view, in absence of any information/circumstances to suggest, in some form or manner, any diversion of working capital loans for funds by the Appellant, in the facts and circumstances of the present case, the presumption drawn by the Assessing Officer cannot be sustained as it has no basis. - AT....